Legal Opinion

Ohio Pike Sav. & Loan Co. v. Commissioner

United States Tax Court

Decided December 2, 1970No. Docket No. 649-69Published

The Commissioner disallowed several deductions -- including the deduction for additions made to a bad debt reserve for qualifying real property loans -- claimed for the taxable year by T, a domestic building and loan association. The deduction for additions to the bad debt reserve was disallowed because T did not fulfill the accounting requirements of sec. 593, I.R.C. 1954, and the regulations thereunder. T does not dispute the disallowance of these deductions.

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The Commissioner disallowed several deductions -- including the deduction for additions made to a bad debt reserve for qualifying real property loans -- claimed for the taxable year by T, a domestic building and loan association. The deduction for additions to the bad debt reserve was disallowed because T did not fulfill the accounting requirements of sec. 593, I.R.C. 1954, and the regulations thereunder. T does not dispute the disallowance of these deductions. The effect of these adjustments was to increase T's taxable income for the year in issue. The amount of taxable income is a factor to…

1Opinion of the Court

Ohio Pike Savings and Loan Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Ohio Pike Sav. & Loan Co. v. Commissioner

Docket No. 649-69

United States Tax Court

55 T.C. 388; 1970 U.S. Tax Ct. LEXIS 22;

December 2, 1970, Filed

Decision will be entered for the respondent.

The Commissioner disallowed several deductions -- including the deduction for additions made to a bad debt reserve for qualifying real property loans -- claimed for the taxable year by T, a domestic building and loan association. The deduction for additions to the bad debt reserve was disallowed because T did not…

2Cases cited5 opinions

  1. Rio Grande Bldg. & Loan Ass'n v. CommissionerUnited States Tax Court · 1961
  2. Colorado County Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1961
  3. Commercial Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1969
  4. Leesburg Federal Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1970
  5. Ohio Pike Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1970

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